April 19, 2022 – Renzulli Law Firm is aware of several recent circumstances in which the ATF is instituting revocation proceedings against federal firearms licensees (FFLs) where the cases had been previously closed after a warning conference.  It appears the ATF is not only taking a “zero tolerance” approach to current situations and audits, but also reviewing prior “closed” cases to determine if the past conduct qualifies under the Biden Administration’s new threshold level for revocation.
As noted in the ATF’s Federal Firearms Licensee Quick Reference and Best Practices Guide, which was updated and revised in December 2021:

ATF will, absent extraordinary circumstances, initiate proceedings to revoke the license of any dealer that has committed a willful regulatory violation of the Gun Control Act (GCA) for specified violations. These violations are: Transferring a firearm to a prohibited person; failing to run a required background check; falsifying records, such as a firearms transaction form; failing to respond to an ATF tracing request; or refusing to permit ATF to conduct an inspection in violation of the law. 

However, ATF now appears to be initiating revocation proceedings for violations previously deemed to be non-willful and thought to be insufficient to justify revocation.  Renzulli Law Firm has a long history of successfully representing licensed firearms dealers in both administrative and court proceedings involving the ATF.  

If you have received a notice of revocation of your FFL, a report of violations, or a warning letter, or you have attended a warning conference in the last several months, please contact John F. Renzulli or Christopher Renzulli for assistance in an effort to avoid the potential revocation of your FFL.